Our systems currently work effectively in response to competitive market driven forces. These systems were developed, and work well, under the concepts of the voluntary NAIS cooperatively developed by industry and involved agencies. I am very concerned, however, about the effects of the latest USDA proposals and initiatives. Moving to mandatory animal ID will change our system from a flexible, market-driven approach to a rigid bureaucratic system that gets in the way of good business management of our operations and adds additional risks and potential liabilities.

2. In an attempt to ensure compliance with the health and safety provisions contained in USDA's rule that reopened the Canadian border to imports of live Canadian cattle, despite Canada's ongoing BSE outbreak, USDA required, beginning in July 2005, that all Canadian imports be permanently and individually identified with eartags and brands (cattle imported in sealed trucks for immediate slaughter were exempted). However, the OIG reported that USDA did not adequately meet required health and safety provisions designed to prevent the introduction of BSE. In a March 2008 report, the OIG found that over 142,000 identified cattle and swine from Canada were slaughtered in U.S. slaughtering establishments without USDA ensuring that proper import protocols were in place, that USDA could not ensure that identified Canadian cattle even arrived at approved slaughtering establishments, and that there were 145 indications of non-compliance with the health and safety standards contained in the agency's rule. In addition, another OIG report revealed that USDA was not properly performing and/or enforcing ante-mortem inspections of cattle at slaughter and that a measure crucial to the protection of human health - the removal of specified risk materials (SRMs) - is not being performed properly, even at plants that slaughter cull cattle that have an inherently higher risk for BSE. Thus, while individual animal identification was touted as a mitigation measure to help prevent the introduction and spread of BSE, as well as to prevent human exposure to the disease, the mandatory individual identification of Canadian cattle functioned as a false panacea that has effectively subjected the U.S. cattle herd and consumers to increased health risks.

R-CALF USA fully supports the mandatory identification of all imported cattle with a permanent hot-iron brand that would conspicuously denote the animals' country-of-origin. However, the importation of foreign cattle subject to such mandatory animal identification should only be allowed following a scientific determination that the country-of-origin of the imported cattle presents no known risk for any serious communicable disease. Because mandatory animal identification can neither prevent the introduction of disease, nor even mitigate potential introduction of disease, the purpose of such mandatory animal identification for imported cattle would be to facilitate the location and monitoring of cattle imported from a country that experiences a communicable disease outbreak subsequent to the scientific determination that the disease was not known to exist in that country.

snip...

In other words, USDA decided to impose a national animal identification system on U.S. livestock producers and then it invented the need to achieve 48-hour disease traceback capabilities in order to justify and legitimize its pursuit.

they put in a 48-hour disease outbreak traceback many many years ago, except to this day, USDA et al have failed, up to one point about 8 months on that Texas mad cow, then 4 months on another suspect BSE that turned out to be negative in part in my opinion negative, due the way the sample was preserved. all this to hold back any other confirmations of BSE in the USA so the infamous OIE/USDA BSE MMR policy could go into effect. that made legal, the exporting of TSE tainted materials.

Because of their responsibility for examining condemned or BSE-suspect animals, NVSL is the organization responsible for activating the notification and BSE response process. It is NVSL that will begin the activation of the BSE Response Plan. From the time a sample is submitted, it takes 14 to 18 days to confirm a diagnosis of BSE In the first 10 to 13 days, pathologists at NVSL have enough information to either rule out BSE or determine the need for additional tests. If it is determined that there is no evidence of BSE, the results are added to the more than 7,500 others that have also been negative. NVSL maintains these data. If additional tests do suggest a presumptive diagnosis of BSE, an NVSL pathologist will hand carry the sample to the United Kingdom for confirmation. It is at this critical point, when NVSL suggests a diagnosis of BSE and is preparing to send the sample to the United Kingdom, that this BSE Response Plan is initiated. The Plan begins the preliminary notification from NVSL to APHIS.

Prelimanary Notification

The director of NVSL is responsible for immediately notifying the APHIS, Veterinary Services (VS) deputy administrator when tests suggest a presumptive diagnosis of BSE. Once NVSL has made a presumptive diagnosis of BSE, APHIS and FSIS field activities will also be initiated. APHIS will receive notification (either confirming or not confirming NVSL's diagnosis) from the United Kingdom anywhere between 24 and 96 hours. (The international animal health community has recognized the United Kingdom's Central Veterinary Laboratory {CVL} as the world's reference laboratory for diagnosing BSE. Other countries, including Belgium, France, Ireland, Luxembourg, the Netherlands, Portugal, and Switzerland, have all sent samples to this lab to confirm their first case of BSE).

NVSL

NVSL will provide all laboratory support in carrying out this BSE Response Plan and serve as the liaison with CVL. NVSL will prepare its facility to receive and process additional samples from the suspect animal's progeny or herdmates or other suspects. NVSL will also coordinate any other assistance from State or university diagnostic laboratories if necessary.

I thought it might be interesting for those of you who have not seen this plan, to do so. So here it is...........

The mission of the U.S. Department of Agriculture (USDA) is to enhance the quality of life for the American people by supporting production agriculture; ensuring a safe, affordable, nutritious, and accessible food supply; caring for agricultural, forest, and range lands; supporting sound development of rural communities; providing economic opportunities for farm and rural residents; expanding global markets for agricultural and forest products and services; and working to reduce hunger in America and throughout the world.

USDA's Animal and Plant Health Inspection Service (APHIS) is responsible for ensuring the health and care of animals and plants. APHIS improves agricultural productivity and competitiveness and contributes to the national economy and the public health. USDA's Food Safety and Inspection Service (FSIS) is responsible for protecting the Nation's meat and poultry supply--making sure it is safe, wholesome, unadulterated, and properly labeled and packaged. These two agencies have come together to lead USDA's actions in the prevention, monitoring, and control of bovine spongiform encephalopathy (BSE) in the U.S. livestock and food supply. The public knows BSE as "MAD COW DISEASE", a disease linked to human cases of new-variant Creutzfeldt-Jakob disease (nvCJD). USDA knows BSE as the disease that devastated the livestock industry in the United Kingdom and shattered consumer confidence in Europe. BSE has affected international trade and all aspects of the animal and public health communities. It has called even greater attention to the U.S. Government's accountability for a safe food supply. No case of BSE has ever been found in the United States. Since 1989, USDA has had a number of stringent safeguards in place to prevent BSE from entering the country. USDA conducts an ongoing, comprehensive interagency surveillance program for BSE. This surveillance program allows USDA to monitor actively for BSE to ensure immediate detection in the event that BSE were to be introduced into the United States. Immediate detection allows for swift response. As an emergency preparedness measure, USDA has developed this BSE Response Plan to be initiated in the event that a case of BSE is diagnosed in the United States. The Plan details comprehensive instructions for USDA staff as to who is to do what, when, where, and how in the event that BSE were to be diagnosed in the United States.

BACKGROUND

APHIS is responsible for being prepared for potential FOREIGN animal disease outbreaks. The purpose of such preparation is to provide a step-by-step plan of action in the event that a FOREIGN animal disease, such as BSE, is detected in the United States. These plans, often referred to as "RED BOOKS", provide guidance by outlining certain actions that should take place, such as identification of a suspect animal, laboratory confirmation, epidemiologic investigation, and animal and herd disposition activities. Copies of Red Books for specific FOREIGN animal diseases are distributed to agency headquarters and each regional and field office to have in preparation for a disease outbreak.

In 1990, APHIS developed a plan to respond to a confirmation of BSE in the United States. In August 1996, a joint APHIS-FSIS working group updated the BSE Red Book in accordance with current science and research surrounding BSE and the related family of disease called transmissible spongiform encephalopathies (TSE's). The BSE Red Book is officially entitled BSE EMERGENCY DISEASE GUIDELINES. The APHIS-FSIS working group determined that the BSE Red Book, which detailed laboratory and field activities to be carried out in an emergency, needed another component. After the March 1996 announcement by the United Kingdom that BSE was linked to nvCJD, it became apparent to the working group that the Plan needed to address communication issues, both internally within USDA and the Federal Government and externally to the public at large. A confirmed case of BSE would affect such a vast array of stakeholders-consumers, cattle producers, the food animal industry, international trading partners, animal and public health communities, media, and others. Having clear, accurate information readily available would build trust and credibility and facilitate any response measures needed. There needed to be a notification plan. Who was responsible for notifying who, what, when, and how? The plan needed to identify clear channels of communication as to ensure immediate collection and dissemination of accurate information. The joint APHIS--FSIS working group became formally known as the BSE Response Team and is responsible for the development of this BSE Response Response Plan. BSE Response Team members represent a mix of backgrounds and expertise, including veterinary medicine, food safety, public health, epidemiology, pathology, international trade, and public affairs. The Team is coordinatied by two Team Leaders, one each from APHIS and FSIS, who serve as liaisons and technical advisors to their respective agencies on regulations and policies regarding BSE. Over the past 2 years, the BSE Response Plan has been reviewed, edited, revised, and approved by officials at all levels of APHIS, FSIS, and USDA. The Plan has also been shared with other Government agencies, such as the Food and Drug Administration (FDA), the Centers for Disease Control and Prevention (CDC), and the National Institutes of Health (NIH), and other stakeholders, such as the Animal Ag Coalition. The BSE Response Team monitors and assesses all ongoing events and research findings regarding TSE's. The Team leaders are responsible for ensuring that prevention and diagnostic measures are continually revised and adjusted as new information and knowledge become available.

NOTIFICATION: Roles and Responsibilities

Surveillance

As part of USDA's surveillance program for BSE in the United States, veterinary pathologists and field investigators from APHIS and FSIS have received training from British counterparts in diagnosing BSE. FSIS inspects cattle before they go to slaughter; these inspection procedures include identifying animals with central nervous system conditions. Animals with such conditions are considered suspect for BSE, prohibited from slaughter, and referred to APHIS for examination as explained below. Pathologists at APHIS National Veterinary Services Laboratories (NVSL) histopathologically examine the brains from these condemned animals. In addition, samples are tested using a technique called immunohistochemistry, which tests for the presence of the protease-resistant prion protein (a marker for BSE). NVSL also examines samples from neurologically ill cattle and nonambulatory ("DOWNER") cattle identified on the farm or at slaughter and from rabies-negative cattle submitted to veterinary diagnostic laboratories and teaching hospitals.

NOTIFICATION

Because of their responsibility for examining condemned or BSE-suspect animals, NVSL is the organization responsible for activating the notification and BSE response process. It is NVSL that will begin the activation of the BSE Response Plan. From the time a sample is submitted, it takes 14 to 18 days to confirm a diagnosis of BSE In the first 10 to 13 days, pathologists at NVSL have enough information to either rule out BSE or determine the need for additional tests. If it is determined that there is no evidence of BSE, the results are added to the more than 7,500 others that have also been negative. NVSL maintains these data. If additional tests do suggest a presumptive diagnosis of BSE, an NVSL pathologist will hand carry the sample to the United Kingdom for confirmation. It is at this critical point, when NVSL suggests a diagnosis of BSE and is preparing to send the sample to the United Kingdom, that this BSE Response Plan is initiated. The Plan begins the preliminary notification from NVSL to APHIS.

Prelimanary Notification

The director of NVSL is responsible for immediately notifying the APHIS, Veterinary Services (VS) deputy administrator when tests suggest a presumptive diagnosis of BSE. Once NVSL has made a presumptive diagnosis of BSE, APHIS and FSIS field activities will also be initiated. APHIS will receive notification (either confirming or not confirming NVSL's diagnosis) from the United Kingdom anywhere between 24 and 96 hours. (The international animal health community has recognized the United Kingdom's Central Veterinary Laboratory {CVL} as the world's reference laboratory for diagnosing BSE. Other countries, including Belgium, France, Ireland, Luxembourg, the Netherlands, Portugal, and Switzerland, have all sent samples to this lab to confirm their first case of BSE).

NVSL

NVSL will provide all laboratory support in carrying out this BSE Response Plan and serve as the liaison with CVL. NVSL will prepare its facility to receive and process additional samples from the suspect animal's progeny or herdmates or other suspects. NVSL will also coordinate any other assistance from State or university diagnostic laboratories if necessary.

APHIS, VS DEPUTY ADMINISTRATOR

Veterinary Services is the animal health arm of APHIS and the program responsible for carrying out field actions in response to BSE. Upon notifiction of a presumptive diagnosis from NVSL, the APHIS, VS deputy administrator immediately notifies the FSIS, Office of Public Health and Science (OPHS) deputy administrator. APHIS and FSIS deputy administrators will alert the BSE Response Team and activate the Response Plan. The VS deputy administrator serves as the liaison between the BSE Response Team and the APHIS administrator. The APHIS, VS deputy administrator notifies the APHIS administrator and the VS regional director of the State from which the suspect animal originated.

APHIS Administrator

The APHIS Administrator immediately notifies the USDA Assistant Secretary for Marketing and Regulatory Programs. This immediate notification will be followed by an official informational memorandum from the APHIS Administrator, through the Assistant Secretary for Marketing and Regulatory Programs, to the Secretary of Agriculture. This memorandum will be prepared by the BSE Response Team; a draft is maintained by the Team leaders in the reserved section of their plans. The APHIS Administrator is responsible for securing indemnity funds for depopulation of the herd if CVL confirms NVSL's diagnosis.

Assistant Secretary for Marketing and Regulatory Programs

The Assistant Secretary for Marketing and Regulatory Programs, in conjuction with the Undersecretary for Food Safety, is responsible for notifying the Secretary. The Assistant Secretary serves as the liaison between APHIS and Department-level officials.

Secretary of Agriculture

The Secretary has the authority to declare a Federal EMERGENCY if appropriate and approve funding as necessary. Information will be provided to the Secretary up the chain of command from the BSE Response Team.

FSIS, OPHS Deputy Administrator

The OPHS Deputy Administrator, together with the APHIS, VS Deputy Administrator, alert the BSE Response Team leaders and instruct them to assemble the BSE Response Team and activate the Plan. The OPHS Deputy Administrator serves as the liaison between the BSE Response Team and the FSIS Administrator. The OPHS Deputy Administrator is responsible for notifying the FSIS regional director in charge of the State from which the suspect animal originated.

FSIS Deputy Administrator

The FSIS Deputy Administrator is responsible for notifying the Undersecretary for Food Safety.

Undersecretary for Food Safety

The Undersecretary for Food Safety, in conjuction with the Assistant Secretary for Marketing and Regulatory Programs, notifies the Secretary of Agriculture.

APHIS, VS, Regional Director

The APHIS, VS regional director in charge of the State from which the suspect animal originated notifies the VS Area Veterinarian-in-Charge (AVIC) for that State. The regional director is the liaison between VS field staff and the VS Deputy Administrator at headquarters. In addition, the regional director shares all information with the BSE Response Team.

APHIS, VS, AVIC

The VS AVIC, in cooperation with State animal health authorities, is responsible for coordination the field activities surrounding the emergency response to BSE. The AVIC assembles the local VS staff to initiate activities outlined in the BSE Red Book including tracing the progeny and herdmates of the suspect animal and beginning an epidemiologic investigation. The VS AVIC coordinates with the State Veterinarian to quarantine the suspect animal's herd of origin. The State has the authority to order a routine quarantine for a neurological disease. The BSE Response Team surveyed every State to determine if they would utilize this authority in the event that NVSL identifies a presumptive diagnosis of BSE. All States responded that they would issue a quarantine.

BSE Response Team

The BSE Response Team leaders will notify each team member and instruct them to assemble in the Situation Room at APHIS headquarters in Riverdale, MD. The Team leaders are responsible for ensuring that all of the Team's duties are fulfilled. It is their responsibility to ensure that the technical information and expert recommendations reach the decisionmakers in a timely fashion. Together with VS Emergency Programs staff, the Team leaders will obtain APHIS, VS administrative support staff in Riverdale, MD, to ready the room for use as BSE headquarters. The Team will begin gathering and assembling information from APHIS and FSIS region and field staff. The Team will pull the draft documents from the third section in the Team leaders manuals and begin filling in current information as it becomes available.

Public Notification

Should NVSL receive notice from CVL confirming a case of BSE, the next level of notification is activated. Each player will follow the same notification protocol as described above for preliminary notification to confirm the diagnosis of a case of BSE.

BSE Response Team

The BSE Response Team will complete the informational memorandum for the Secretary. The Team will prepare the letter to the Office of International Epizootics (OIE), the international animal health organization, for signature by the APHIS, VS Deputy Administrator. OIE requires that all countries submit official notification within 24 hours of confirming a diagnosis of BSE. The BSE Response Team and the office of the APHIS, VS Deputy Administrator would coordinate a teleconference to inform all APHIS regional directors and AVIC'S. The BSE Response Team and the office of the FSIS, OPHS Deputy Administrator would coordinate a teleconference to inform all regional and field FSIS offices. The BSE Response Team would coordinate a teleconference to notify other Federal agencies. The BSE Response Team would coordinate a teleconference to notify key industry/consumer representatives. The BSE Response Team and APHIS International Services would notify foreign embassies. The BSE Response Team would establish a toll-free 800 telephone line for industry representatives, reporters, and the public. The BSE Response Team would coordinate with APHIS Legislative and Public Affairs and USDA office of Communications to issue a press release the day the diagnosis is confirmed. The press release would announce a press conference to be held the morning after the diagnosis is confirmed......

The section below would be implemented only after a first case of BSE is confirmed in the United States.

7.1 READEO Activation

READEO activation will rarely be necessary for BSE outbreaks. Different from most other foreign animal diseases and infectious diseases, BSE is not a rapidly spreading, acute epizootic; is not thought to be transmitted horizontally between animals within a herd, has an extremely long incubation period, and usually affects only isolated single animals or, at most, a few animals within herds. Because BSE does not spread rapidly, the workload to investigate and manage most outbreaks should not normally exceed the capability of existing local field personnel. READEO activation should be considered only if the particular circumstances of a BSE outbreak warrant. If field personnel feel they are unable to manage a BSE outbreak, they should communicate this to their Regional Director and VS, Emergency Program staff, who will evaluate the need for READEO activation.

7.2 READEO Organization

If READEO is activated, a reference should be made to the revised READEO Manual for further guidance on READEO organization and operations.

7.2.1 Office of the Director When an animal disease emergency exists, the Task Force Directors are responsible for the READEO activities. The directors immediately move to the location of the outbreak and setup the READEO headquarters. Work is coordinated with State officials of the States involved in the outbreak. 7.2.1.1 State Director--(Note: This is the new designation for the Assistant Director.) Each READEO may have one or more State Directors since each State where the disease outbreak is found will be represented in the READEO by State officials designated by the State Veterinarian. 7.2.1.2 Emergency Program Officer--This individual, designated by the Chief Staff Veterinarian of VS, Emergency Programs, provides liaison between the READEO and the Emergency Programs at APHIS headquarters. 7.2.1.3 Public Affairs Officer--The Public Affairs Officer plans, develops, supervises, and maintains information activities for the READEO. 7.2.1.4 Legal--The Legal Advisor provides counsel and assistance to the READEO. 7.2.1.5 Military--The U.S. Armed Forces Command will designate a senior line officer to be the Military Support Officer on the staff of the READEO Task Force Directon The individual is assigned to be the liaison between the Depart-

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ment of Defense and VS, Emergency Programs,and to coordinate needed military assistance during eradication of an FAD outbreak. 7.2.1.6 Meat and Poultry Inspection Operations--The Meat and Poultry Inspection Operations, Food Safety and Inspection Service, will designate personnel to report to the READEO Task Director and to provide liaison between the Task Force and the Meat and Poultry Inspection Operations. 7.2.1.7 Laboratory Coordination--The Laboratory Coordination Officer will advise the READE(3 Director concerning laboratory capabilities and appropriate laboratory examinations to be conducted to provide needed results as rapidly as possible. This individual will assist with interpretation of results.

7.2.2 Administration The Administrative Officer assigned to the READEO will direct and coordinate all facets of general administrative functions. Refer to the revised READEO Manual for a detailed description of the organization and responsibilities.

7.2.3 Field Operations The Field Operations Officer will direct line operations and supervise field personnel in a READEO. Disease investigation, field epidemiology, disease security and personnel security, animal movement control and quarantine enforcement, appraisals of animals and materials, depopulation and disposal, and cleaning and disinfection are among this person's responsibilities.

7.2.4 Technical Support Staff support consists of a technically competent staff designed to act as a resource for the READEO Task Force. Personnel may include but are not limited to individuals who have expertise in the following areas: animal welfare, data systems, disease reporting, economics, environmental impact, epidemiology, evaluation, orientation and training, risk analysis, and wildlife. The staff communicates the needs of the Field Epidemiology Delivery System (FEDS) to the READEO Director as required to maintain an efficient, accurate, up-to-date FEDS. 7.2.4.1 Animal Welfare---Animal Welfare Officers must be knowledgeable about current Federal and State animal welfare regulations, humane methods of animal depopulation, and socioeconomic concerns related to animal welfare issues. They advise the technical support staff and field operations concerning current procedures and accepted methods for use in the humane depopulation of livestock and poultry. 7.2.4.2 Wildlife-- Wildlife Officers participate with the Director and other officials of the READEO to establish and carry out wildlife policies and objectives for the emergency animal disease operation. Through familiarity with the topography, wildlife density, susceptible wildlife species, and movements of susceptible wildlife, the Wildlife Officers can review maps and make recommendations concerning areas to be included in the quarantined high-risk and buffer zones. These officers maintain contact with local, State, and Federal wildlife enforcement officers and wildlife biologists. They develop strategies for conducting surveys of susceptible wi!dlife in the outbreak

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area to determine the incidence of the disease. They direct and coordinate the vaccination and depopulation of wild animals as necessary to eliminate the disease.

7.3 Supplies and Equipment

During an outbreak of BSE, supplies and equipment should be obtained through normal procurement procedures. If a READEO is activated, supplies and equipment should be ordered through the READEO Procurement and Supply Officer.

During a BSE outbreak, field personnel should follow instructions issued through the normal chain of command. If a READEO is activated, personnel should refer to the revised READEO Manual for detailed descriptions of individual responsibilities.

7.4.1 Personnel Personnel assigned to the READEO Task Force are individually accountable for equipment and supplies checked out to them. They should order replacement equipment and supplies or return equipment for repairs through the READEO Procurement and Supply Officer. All damages or losses to equipment or vehicles should be reported immediately to the READEO Administrative Officer, and the required forms should be completed and submitted promptly.

7.4.2 Travel Employees of the READEO Task Force are responsible for recording and preparing all travel-related documents. Claims for travel, lodging, per diem, and incidental expenses should be submitted to the READEO Administrative Officer for processing.

7.4.3 Vehicles Employees of the READEO Task Force are responsible for operating, cleaning, and performing routine maintenance of assigned vehicles. They also are responsible for recording mileage, expenses, and services. Required reports are to be submitted to the READEO Vehicle Officer.

7.4. 4 Clothing Employees of the READEO Task Force are issued protective clothing to wear when entering a premises where BSE has been diagnosed or is suspected. Clean clothing should be worn on each premises. Employees are responsible for laundering the clothing before reusing it.

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In a large task-foree operation, arrangements may be made for a commercial laundry service to handle the clothing. If it is possible and practical, all clothing should be labeled to identify the employees to whom it is assigned.

7.4.5 Miscellaneous Responsibilities Employees are responsible for conducting their assigned tasks in a professional manner. Complaints concerning task force employees should be directed to the READEO Director for resolution or appropriate action.

All animals, products, and materials to be destroyed because of BSE should be appraised according to 9 CFR 53.3 and appropriate State regulations.

7.5.1 Appraisal Teams Appraisals must represent the interests of the owner, the State, and the Federal Government and be consistent with fair market values. If State authorities approve, State and Federal interests may be represented by a VS employee alone. Owners may, at their discretion and expense, employ a professional appraiser to advise them or to act as their agent. Either the owner or the owner's agent must be present at appraisals. No animals may be destroyed until after the appraisal forms are signed by the owner or the owner's agent. Appraisers should be certain that the owner or the owner's agent is aware of the indemnity form's clause concerning liens and mortgages. When the number of animals to be destroyed is small, and the total value of animals, products, and materiais is low, APHIS field personnel may negotiate the appraised value with the animal's owner without assistance from a professional appraiser. The appraised value of a BSE suspect should be the slaughter value of the animal, taking into account any existing defects or diseases that would affect the slaughter value but ignoring those signs that caused the animal to be classified as a BSE suspect. If field personnel are in doubt concerning the need to use a professional appraiser, they should consult their supervisor or VS, Emergency Programs staff. If a determination is made that healthy progeny, ova, semen, or embryos must be destroyed, they should be appraised at 100 percent of replacement value. Feeds or feed ingredients located on suspect farms will rarely need to be destroyed. If a determination is made that feeds or feed ingredients must be destroyed (for example, to comply with a policy decision to remove all rendered products from animal feeds), then these materials should be appraised and indemn'ff~ed according to 9 CFR 53.3.

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7.6 Depopulation Procedures

7.6.1 Factors and Considerations If the owner is agreeable, a humane method of euthanasia of BSE suspects will be necessary to facilitate the accurate diagnosis of the disease problem, to ensure that the suspect animal is not slaughtered or rendered, and to terminate the animal's suffering. Under no circumstances may BSE suspects be sent fo slaughhter or rendering. Notify FDA, CVM if you suspect that the carcass of a BSE-confirmed animal has moved to rendering or animal feed manufacturing. The VS, Emergency Programs staff, Riverdale, MD, must authorize the use of euthanasia, depopulation, and indemnity payments for READEO operations.

7.6.2 Humane Euthanasia Methods Only experienced veterinarians should perform euthanasia because there are inherent dangers. Precautions should be taken to prevent accidents. Owners should be given a complete explanation of what to expect, and only humane euthanasia methods should be used. Euthanasia should be performed away from public view, and, if possible, the owner should not be present. Euthanized animals must be checked to confirm death. (See VS Memo 583.1, 1992.) 7.6.2.1 Mechanical (Firearms)--Because the only acceptable method for euthanizing an animal by using firearms is to shoot it in the head, and because the animal's brain must be preserved to diagnose BSE, firearms are not an acceptable euthanasia method. 7.6.2.2 Chemicals(Toxic Gas or Lethal Injection)--Follow guidelines established by the American Veterinary Medical Association. When using a regulated controlled substance (e.g., barbiturates), control and administration of the euthanasia agent must be given by a veterinarian having a Drug Enforcement Administration (DEA) number issued by the U.S. Treasury. Control and administration of chemical substances for euthanasia must be authorized by the AVIC unless directed by the VS Deputy Administrator. (See VS Memorandum 583.1, 1992.)

7.6.3 Supervision of Depopulation Field personnel should never perform depopulation or euthanasia without explicit permission from their supervisor or, if appropriate, the READEO Humane and Disposal Officer. (Refer to the revised READEC) Manual.)

7. 6.4 Permits for Movement All BSE suspects may be moved under permit to facilitate medical treatment, euthanasia, necropsy examination, or carcass disposal. Permitted movement will be according to the quarantine restrictions and will be administered by the State or Federal officials.

7.7 Disposal Under no circumstances may BSE suspects be sent to slaughter or rendering. Notify FDA, CVM if you suspect that the carcass of a BSE-confirmed animal has moved to rendering or animal feed manufacturing. Field personel should arrange for the carcass to be transported to and examined by a qualified veterinary pathologist or field veterinary medical officer. After the pathologic examination has been completed and the necessary diagnostic specimens have been obtained, field personnel should arrange for disposal of the carcass. Before a method of disposal is selected, there are many factors that must be considered, and often other State and Federal agencies must be consulted. The environmental and legal impacts of the operation must be considered. Upon recommendation of the State or Federal agencies, VS may consider other disposal methods.

7.7.1 Incineration Incineration, although more expensive than burial, is the preferred disposal method for BSE-suspect carcasses. Federal, State, and local environmental regulations may restrict the use of this method and permits may be necessary. As soon as BSE suspects are reported to APHIS, field personnel should investigate the location and availability of incinerators of sufficient size to process a bovine carcass. Institutions likely to have incinerators include State and university diagnostic laboratories, waste contractors, large municipalities, and private industries. Ideally, the diagnostic laboratory where the pathologic examination was done will have incineration facilities. The BSE-suspect carcass disposal is APHIS' responsibility (not the diagnostic laboratory's). Field personnel should arrange for transportation and final disposal of the suspect carcass and should inform their supervisors and/or the READEO Humane and Disposal Officer of these arrangements. Personnel should be aware that some laboratories dispose of carcasses by rendering and should specifically inquire if this is the case. CNS suspects should be incinerated or held from rendering until a diagnosis of BSE can be ruled out. Under no circumstances may BSE susuects be sent to slaughter or rendering. Notify FDA, CVM if you suspect that the carcass of a BSE-confirmed animal has moved to rendering or animal feed manufacturing. Field personnel should be prepared to accompany the carcass from the farm of origin to the diagnostic laboratory and then to the disposal site if any doubt exists concerning the final disposal method.

7.7.2 Burial If there are no other avenues for carcass disposal, burial of BSE-suspect carcasses may be an acceptable disposal method. APHIS field personnel should inquire with environmental authorities concerning Federal, State, and local regulations that may impose restrictions on this method. The burial site may be on the affected farm, at the diagnostic laboratory where the carcass is examined, or in a local landfill. The site should be inaccessible to animals, removed from populated areas, not used for agricultural purposes, clearly marked, and properly protected.

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Burial sites should also be located a sufficient distance from underground utility lines, septic systems, water wells, and surface water. Local environmental or public works officers may be helpful in locating a satisfactory site. Field personnel should consult with their supervisors and/or the READEO Environmental Impact Officer before digging. Burial trenches are normally at least 9 feet deep with floor dimensions of 7 by 2 feet per adult bovine carcass. Carcasses should be covered with at least 6 feet of soil. This soil should not be tightly packed because gas formation may cause a tightly packed trench to crack and leak.

7.7.3 Rendering Because BSE is spread by rendered animal protein, BSE-suspect and confirmed carcasses must not be rendered, unless the rendered material is incinerated. Notify FDA, CVM if you suspect that dead BSE animals or carcasses have moved to rendering or animal feed manufacturing.

7.7.4 Other Disposal Methods The AVIC, the State animal health officials, and the READEO Director may recommend other methods of disposal to the Deputy Administer, VS, for approval (9 CFR 53.4). Options for disposal must be discussed and approved by VS, Emergency Programs staff and must comply with all State and local Environmental Protection Agency regulations.

7.8 Cleaning and Disinfecting (C&D)

Although BSE is neither contagious nor vector borne, appropriate C&D is required to prevent farm-to-farm transmission of most other infectious diseases. Field personnel must remember, however, that at the time they are requested to euthanize a BSE-suspect animal, a confirmed diagnosis of BSE will not be available. Signs compatible with BSE may be caused by numerous infectious diseases and many BSE-suspect animals will, in fact, have some other disease. Although the C&D of items such as manure, bedding, feed, stalls, halters, milking machines, and other supplies and equipment that have been in contact with BSE suspects is not specifically necessary to control BSE, C&D is still advisable to control other diseases that may be present.

7.8.1 Procedures for Cleaning and Disinfecting 7.8.1.1 Premises and Items--Field personnel are not responsible for C&D of premises such as barns, stalls, and animal pens unless invasive diagnostic procedures (such as a necropsy examination or the removal of the suspect animal's brain) were performed on the premises. If possible, field personnel should avoid doing such procedures on the farm. If circumstances require that such procedures must be done on the farm, personnel should clean and disinfect the immediate area after completing the work. 7.8.1.2 Vehicles--Vehicles used to transport personnel to affected premises should be kept clean, and normal precautions against the farm-to-farm spread of any disease should be observed.

October 1998

BSE Red Book 2.1-42

7,8.1.3 Carriers--Thoroughly clean trucks and trailers transporting BSE suspects. Manure and bedding may be disposed of by any environmentally accepted method such as spreading on fields or composting. After conveyances have been thoroughly cleaned, disinfectant should be sprayed on the sides and floor of the truck bed. 7.8.1.4 Livestock Markets--The risk of BSE transmission at livestock markets is negligible. If a BSE suspect is found at a livestock market, it should be managed the same as if it were found at a farm. Because of the high risk of transmission of diseases other than BSE, invasive diagnostic procedures, such as a necropsy examination or removal of the suspect animal's head, should not be performed at livestock markets. Due to the recent research findings concerning maternal transmission, any pens or areas in which calving occurs should be thoroughly cleaned and disinfected. Cleaning and disinfection is not necessary to prevent the spread of BSE. However, the C&D procedures are recommended to prevent the spread of other diseases from pens or buildings where BSE suspects were held. 7.8.1.5 Slaughter Plants--Becanse BSE is spread by rendered animal protein in cattle feeds, BSE suspects must not be slaughtered nor rendered. If a BSE suspect is found at a slaughter plant, it should be managed similarly to finding a suspect at a farm.

7.8.2 Approved Disinfectants Field personnel should use professional judgment in the choice of a disinfectant. Preferred disinfectants to inactivate the BSE agent include 1N sodium hydroxide solution or sodium hypochlorite solution containing 2 percent chlorine (1 hour exposure at 20 %C [68 %F]). This should be used whenever there is reason to strongly suspect that BSE is in fact the cause of the suspect animal's disease. Such reasons include previously confirmed BSE in the geographic area or signs more compatible with BSE than with any other neurologic disease. If the suspect animal's signs are more compatible with diseases such as rabies or listeriosis, then a phenolic disinfectant such as "One Stroke" may be preferable. (Refer to appendix A Survival of BSE Agent and sec. 1.4.4.)

7. 8. 3 Precautions All disinfectants are hazardous to human beings, animals, and the environment. Label directions should be carefully read and followed. Many disinfectants, including sodium hypochlorite solution, are also corrosive and should be used with caution on metal and other corrodible materials. Thorough rinsing is necessary if corrosive disinfectants are used on metallic items. Disinfectants, especially in concentrated form, may irritate skin, eyes, and respiratory systems. Protective equipment such as appropriate clothing, rubber boots, rubber gloves, mask and goggles should be worn during mixing and application of disinfectants. If areas of the body are exposed to a disinfectant, they should be washed thoroughly with water. Employees should notify their supervisor and their Health and Safety Officer if excessive human or animal exposure to disinfectants occurs or if there is accidental release into the environment.

October l998

BSE Red Book 2.1-43

Field personnel should use normal hygienic procedures (such as washing and disinfecting boots and removing the outer layer of clothing) when leaving the farm. Unless the disease problem is noncontagious, personnel should not travel to other livestock premises for the duration of that day.

7.9 Vector Control

Current scientific data indicate that BSE is not spread by vectors.

7.10 Disease Prevention and Philosophy

The goal of disease prevention and control is to confine the occurrence of BSE to as few herds as possible and to prevent recycling of the BSE agent in the ruminant food supply. If undiagnosed cases are rendered and included in ruminant rations, the long incubation period may allow many animals to be exposed. Action should be taken immediately after the detection and confirmation of BSE to initiate an extensive epidemiologic investigation to determine the source and extent of the disease, to stop the spread, and to eradicate the disease. 7.10.1 Philosophy--Immediate action should be taken to prevent contamination of the animal food supply by prohibiting rendering of any infected or suspect bovine carcasses. In addition, care should be taken to monitor those animals born and raised in affected herds and to prevent their becoming a source of infection to other herds. 7.10.2 Agent Spread--Epidemiologic evidence indicates that the primary route of BSE transmission is through the feeding of contaminated meat and bone meal that has been manufactured using scrapie infected sheep carcasses or BSE infected bovine carcasses. Recent research findings suggest that maternal transmission may occur at a rate of approximately 1 percent in some species. It is believed that this route of transmission is not significant enough to maintain an epidemic. Cases of apparent maternal transmission have also been identified in captive exotic ruminants. 7.10.3 Control of Products and Conveyances--Carcasses of BSE suspects should be incinerated. Carcasses must not be rendered and incorporated in animal feed. If carcasses are transported for disposal, conveyances should be cleaned and disinfected after use with either a sodium hypochlorite solution (2 percent available chlorine) or 1 N lye (sodium hydroxide solution). 7.10.4 Control of Biologics and Drugs--Although no documented cases of BSE have resulted from the use of biologics derived from bovines, tissues from suspect or exposed animals must not be used for the production of biologics and drugs. The agents responsible for causing the transmissible spongiform encephalopathies are highly resistant to normal inactivation processes. Careful selection of source materials is the best way to secure maximum safety of ingredients or reagents of bovine origin used in the manufacture of biologics or other medicinals. Factors that should be considered are the age of the animals, exposure to the agent, and the tissue or organ from which the product is derived.

October 1998

BSE Red Book 2.1-44

7.10.5 Wild Birds, Wind and Insects---Wild birds, wind and insects are not known factors in the spread of BSE. 7.10.6 Rodents--Rodents are not known factors in the spread of BSE. 7.10.7 Hunting--Restrictions on the hunting of wild animals are not necessary to prevent BSE. 7.10.8 Exhibitions--Cancelling scheduled exhibitions is not necessary. 7.10.9 Rendering Trucks and Drivers--The carcasses from BSE suspects must not be rendered. If any rendering truck is used to transport a suspect, it should be cleaned, washed, and disinfected as above. (Refer to appendix A--Agent Survival and sec. 7.8.2--Disinfectants.) 7.10.10 Treatment--Currently there is no known treatment for BSE. 7.10.11 Prevention--Suspects and animals confirmed to have BSE must not be rendered. Producers, feed mills, and rendering establishments should adhere to U.S. State and local rendering policies and FDA regulations concerning the feeding of rendered animal protein to ruminants. Because of the possibility that some transmissible spongiform encephalopathies may be transmitted at the time of parturition, precautions should be taken to prevent exposure of healthy animal to placenta and reproductive fluids. Importation of live animals and animal products from countries with BSE or having high risk factors for BSE should be restricted based upon scientific risk assessment. 7.10.11.1 Immunization--The agent that causes BSE elicits no detectable immune response in the host. Therefore, vaccination is not a viable option. There is no vaccine currently developed for BSE or other TSE's. 7.10.11.2 Sanitation--Although it is unknown whether a contaminated environment plays any role in the spread of BSE, it is suggested that pens having contained BSE-infected animals be cleaned and disinfected. The disinfectants o choice are sodium hydroxide (lye) and sodium hypochlorite, in infected herds it is also advisable that all placentas be removed promptly and buried or incinerated. The calving pens also should be cleaned and disinfected. 7.10.113 Producer Defense---The most effective way to prevent an intruduction of BSE into a herd is not to feed ruminant byproducts to ruminants. As of August 4, 1997, the FDA has a ban in place which prohibits the feeding of most mammlian proteins to ruminants.

7.11 Records Maintenance in a Foreign Animal Disease Outbreak

The APHIS FEDS will be used by the READEO to record information. FEDS a computerized network designed to transmit accurate information rapidly during any emergency disease outbreak. The use of FEDS will allow the READEO to direct its attention to the minute-to-minute business of containing and eradicating the disease. For an accurate record of the activities, all field supervisors in a READEO task force should maintain a diary. Activities and observations should be recorded in the diary when they occur. Date all documents and enter events by time and date to show a correct chronology. Enter events as they occur in the diary as well. An accurate history is of considerable value in developing policies and plans for future disease-eradication

October 1998

BSE Red book 2.1-45

programs, and it may be important if there is litigation. A diary will be helpful for day-to-day administration of funds, personnel, and equipment. It is also useful as a later reference in preparing reports and summaries of activities.

7.11.1 Daily Reporls Submit daily reports of significant activities to the READEO Director and the VS, Emergency Programs staff Riverdale, MD. (Refer to appendix F for current telephone listings.) Include the following as part of the historical file of an outbreak:

*Maps showing premises where BSE-infected animals were found; *Inventory of feeds and feed sources; *Origin of BSE-suspeet and confirmed animals; *Public information material distributed, newspaper clippings; and, Administrative reports to support the expenditure of funds, utilization of personnel and equipment, and disposition of excess materials and equip­ment at the end of the program.

7.11.2 Distribution The VS, Emergency Programs staff will distribute reports of significant activities to all AVIC's, State cooperators, and industry cooperators at least weekly. As soon as significant events occur, Emergency Programs will inform all APHIS headquarters units through normal reporting channels. Emergency Programs also will immediately report any significant events to the Deputy Administrator, VS, who will immediately advise the APHIS Administrator, especially of legal or politically important events. A weekly summary report of control and eradication activities will be provided to the APHIS Administrator and the Deputy Administrator, VS. See BSE Response Plan, communications section.

7.11.3 Disposition Records should be maintained until a historical account of the program has been prepared and all pertinent information has been gleaned from the records. Furthermore, all records should be maintained if there may be legal action pending as a result of the program activities. Usually, administrative records are maintained a minimum of 3 years for audit purposes.

i am looking now a bizarre Oct 98 internal USDA publication describing a james bond-type US effort to control media should the long-anticipated first case of BSE in the US be admitted.

'Players' on the 27 member BSE Response Team are to be flown in from all over the country to a BSE Headquarters 'situation room' apparently an underground bunker in Riverdale, Maryland under the command of the Assistant Secretary of Marketing.

Authentic press releases are already prepared and ready to go out after a few specifics have been filled in. They are spelled out in a separate document, the BSE Red Book, aka BSE Emergency Disease Guidelines.

Aphis' National Veterinary Services Laboratories (NVSL) activates team assembly. From the time a bovine brain sample is submitted, it takes 14-18 days to confirm a diagnosis of BSE. In the first 10-13 days, NVSL have enough information to determine the need for additional tests. If a provisional BSE diagnosis is made, the sample is 'hand-carried' (are they going to tell the airline and customs?) to the Central Veterinary Laboratory in England for confirmation, where they are expecting a 24 to 96 hour turn-around.

I guess that means we can get the white tiger brain analyzed by Friday despite the 22 year delay to date. Maybe we could throw in a few cougar brains from NE Colorado too.

A Team Member is designated to silently monitor this listserve and www.mad-cow.org (among others) -- for what, it doesn't say. The Freedom of Information Act request from the East Coast consumer group turned up numerous top-secret USDA downloads from that site and Dealler's.

After 24 hours of secret briefings for 'select industry and trading partners' (to allow them to take positions on the commodities markets opposite the 'non-select' industry and trading partners?), a press conference will be held the next day.

There are plans to trace the cow, its lineage, its herdmates, the renderer, traceout of product, buyout of herd, farm of origin, to get the state involved to quarantine the herd (pre-arranged for all 50 states), expectations for trade bans, notification of OIE within 24 hours, media 800 numbers, spokespersons and backups, notify CDC, FDA, NIH, and many other commendable activities. The Flow Chart is a sight to behold, I will try to scan it in tomorrow.

In short, that cow is going to be toast by the time the public first hears about it.

The Plan does not speak to the scenario in which the CVL says, yes, this is bovine spongiform encephalopathy all right but it is one of your strains, not ours. Invoking their Absence of Evidence is Evidence of Absence principle, there may be no perceived need for public disclosure in this case.

USDA is caught completely unprepared if BSE first turns up in a US zoo animal. These animals could easily be diagnosed outside the "system" and be the subject of a publicity-seeking lab press release. I think this is a more likely scenario because the US has likely imported many thousands of zoo animals with advanced infections from Britain and France and there has been zero monitoring. Unlike with downer cows, anyone with the right colleagues can get ahold of a fallen zoo animal. Zoo animals enter the food chain in some cases after being rendered.

Another scenario would be some stock market speculator obtaining the Red Book and issuing a flurry of bogus but authentic-looking press releases that included bogus 800 and hacked USDA web links. The press here is so lazy and so accustomed to putting out public relation handouts as news that the objectives would be accomplished for a few hour (or days, depending on the Response Team's paralysis vis-a-vis off-flow chart events). Some people think a practise run for this happened in the Indiana case a year or two back.

The first case of nvCJD in an American will also be a public relations fiasco. In the dim bulb of the public mind, any American with mad cow disease would have gotten it from eating meat here. USDA has no way to prove that the victim acquired it on a three week trip to England in 1987. This will sound lame even to the press. All CJD is synonymous with mad cow disease in the public perception; the more often the different kinds are explained, the more their suspicions are aroused. The first case of nvCJD in an American will simply validate what they already know and just be viewed as an overdue admission from the government.

tom

___________________________________________________________END

TEXAS MAD COW ATYPICAL h-BSE

Epidemiology Investigation of Index Herd: Farm A

Background

The index cow was an approximately 12-year-old yellow or cream-colored Brahma cross that originated from Farm A located in Texas. The cow was sold through a livestock sale on 11/11/04, purchased by an order buyer, and was transported to a packing plant on Monday, 11/15/04. When the truck arrived at the packing plant during the late afternoon of 11/15/04, the index cow and one other were found dead on the truck and were transported to a pet food plant later that day where they were sampled for BSE testing as part of the enhanced BSE surveillance.

DNA analysis of blood samples taken from five of the six units of cattle that comprise Farm A yielded four animals from two different units that were genetically related to the index cow and confirmed Farm A as her herd of origin.

The herd on Farm A consisted of mixed breed beef cattle that are traditionally not used as seedstock replacement animals. Market records and preliminary tracing indicated that most animals that left the index herd either went to slaughter within a few days of sale or, in the case of younger animals, entered into known rendering and slaughter channels immediately following sale. There were only 11 cows identified during the investigation that were traced from Farm A into other herds where they had been used as replacement cows. The owner of Farm A raised this cow from birth and stated that the cow had never been off the premises prior to its sale. She was marketed because of poor body condition (the animal’s condition had not improved despite the early weaning of her 2003/2004 calf). The owner stated that the cow had always been excitable and had fallen while she was being loaded to go to the market, but that this was not unusual behavior for her in his opinion. In addition there was a report of this cow being down in the alley at the livestock market on 11/11/04, but she apparently got up again and was able to be loaded onto the truck to go to the packing plant. When questioned about any previous history of neurological signs in cattle on the farm, the owner reported that no cattle on the farm had ever shown any neurological signs, nor had there been any cases of rabies on the index farm.

Index Herd Census

Farm A consisted of 6 units (Units A through F) containing a total of about 217 adult cattle and approximately 100 to 120 calves. Early in the investigation, response personnel discovered that an additional unit belonging to the owner’s son and located adjacent to Unit F could also contain COI. This group, Unit G, contained 16 adult cattle and made a seventh unit that became included in the investigation.

On 6/22/05, the first three of the original six units were sampled for DNA testing to confirm the herd of origin of the index cow. Those first three units consisted of: Unit A contained 62 head with some older cattle (more likely than the other units to provide a DNA match); Unit B with 28 head (3-year-old unit); and Unit C with 25 head (2-year-old unit). Two additional units were sampled for DNA on 6/23/05; Unit D with 31 head and Unit E with 30 head, both of which contained older animals.

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The sixth unit, Unit F, containing 41 head, was purchased in 1993 from another source. Because it did not have animals that were genetically related to the other 5 units, this unit was not sampled for DNA testing. Unit F, and adjacent Unit G, contained COI because the weaned heifers from those units were commingled and fed with weaned heifers from the other units for a short period of time before they were returned to their respective units of origin. This practice of weaning and feeding together fit the definition of a feed cohort.

Progeny

The owner did keep some replacement heifers and, although he was relatively sure that he had not kept any offspring from the yellow cow because of her excitable demeanor, DNA analysis of the herd revealed several animals in the herd that may have been older offspring of the index cow. While the owner sold 12 calves at the sale with the index cow on 11/11/04, her last calf was not in that group. According to the owner, the index cow’s last calf was born either in Fall 2003 or Spring 2004, weaned early, and sold through the livestock market some time between February and October 2004. The calf prior to that would have been born either in Fall 2002 or Spring 2003 and was sold at the livestock market sometime between January and December 2003.

Birth Cohort

The owner of Farm A kept very few herd records; this made finding documentation on this cow’s birth cohort difficult. The birth cohort, by definition, included all cattle born on the positive animal’s birth premises within 1 year, before or after, the positive animal’s date of birth. The index cow was approximately 12 years of age in November 2004, but there was no exact birth date in the herd records. A potential age range of 11 to 13 years was used to sufficiently cover the animal’s most likely age. Using this range, all cattle born on the index premises between 1990 and 1995 were considered part of the birth cohort. In lieu of the owner’s records, herd records from Veterinary Services’ Generic Database (GDB) were used to compile a list of brucellosis calfhood vaccination (CV) tag numbers from the index herd that corresponded to animals to be included in the birth cohort. There were 121 animals identified through GDB as having been calfhood vaccinated on the index farm between 1991 and 1994. The owner of Farm A did not calfhood vaccinate after 1994. Moreover, calfhood vaccinates include only heifers. Therefore, the list of 121 animals was not a complete list of all birth cohorts. However the tracing that response personnel conducted on other COI was designed to account for the remainder of the birth cohorts.

Feed Cohort

Animals in Units A, D, and E, that were weaned and fed with the positive cow between 1991-1995, were already considered at-risk as part of the defined birth cohort. Animals in Units B and C were 3-year-olds and 2-year-olds, respectively, and were too young to be either birth or feed cohorts. Although Unit F was purchased separately and did not contain animals genetically related to the other units, calves from Unit F were weaned and fed for a short period of time with weaned calves from other units and all calves were later returned to their respective units of origin. Since Unit F was not purchased until 1993, the feed cohort consisted of those animals in Unit F that could have been weaned and fed with the index cow in 1993 or 1994. Additionally, Unit G contained possible feed cohorts that could have been weaned and fed with the index cow between the years of 1991 and 1995.

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Feed

The feeding regimen for the cattle in this herd consisted of natural pasture, hay, mineral supplement, syrup tubs occasionally, and a breeder’s supplement (predominantly a name brand manufactured breeder’s cube). The Food and Drug Administration (FDA) investigated all sources of feed and supplements used on Farm A. In-depth investigations and site visits were conducted by FDA involving retail feed stores, feed manufacturers, slaughter plants, renderers, and brokers. A more detailed account of the investigation is contained in FDA’s final report.

Removal of Cattle from the Index Farm

Any animal still present within the index herd that could have been a possible birth cohort or feed cohort of the index cow was targeted for removal as an at-risk animal. Units A, D, E, F, and G, all of which were known to contain older animals, were inventoried. Identification tags, tattoos, and brands were recorded, and all animals were aged based on their dentition and any man-made identification. Cattle whose estimated age indicated that they could have been part of the index cow’s birth or feed cohort were removed from the herd, euthanized, and tested for BSE; all were negative.

Units B and C were exempt from the cohort removal process because they contained only 3-year-old and 2-year-old animals respectively. Although the DNA analysis of animals in Units A through E determined that there were 2 animals present that could have been offspring of the index cow, their estimated age by dentition revealed that they were not of the appropriate age to be at-risk progeny. This verified the owner’s claim that he had sold the index cow’s last two calves at the livestock market and they were not currently present in the index herd.

After sorting by age, response personnel identified and removed the following numbers of cows from the herd on 7/6/05: Unit A, 11 cows; Unit D, 11 cows; Unit E, 7 cows. The same process was applied to Units F and G and the following numbers of cows were identified and removed from the herd on 7/7/05: Unit F, 28 cows; Unit G, 10 cows. Of the 67 animals removed from the herd as possible birth cohorts and/or feed cohorts of the index cow, 42 were definitively identified as belonging to the birth cohort due to the presence of a calfhood vaccination tag or tattoo that corresponded to the appropriate birth cohort years. All 67 animals were euthanized on 7/6/05 and 7/7/05 and samples were subsequently sent to USDA’s National Veterinary Services Laboratories (NVSL) for BSE testing. All samples were run on the ELISA test and confirmed negative on 7/8/05 and 7/9/05. Upon confirmation of negative results, disposal of carcasses was completed by burial in an approved landfill facility. The index farm was released from hold order on 7/11/05.

Tracing of Progeny

The 2003/2004 progeny of the index cow was known to have left the farm through a specific livestock market sometime between February and October 2004. The 2002/2003 progeny of the index cow left the farm through the same market sometime between January

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and December 2003. Response personnel learned early in the investigation that animals from the index farm were sold not only under the index farm owner’s name and that of his wife, but also by other members of the owner’s immediate family. Additionally, there were no herd records to indicate the gender of the two at-risk progeny. Therefore, market records for February through October 2004 and January through December 2003 were obtained for all calves sold both by Farm A’s owner and by members of his immediate family; response personnel traced all such calves to determine their disposition. With the index herd being composed of mixed breed beef cattle, the calves that left the farm were genetically unsuitable for use as replacement animals or for sale as breeding stock, a fact that was confirmed by the trace work and the documentation of the final disposition of the calves of interest.

Response personnel ultimately identified 213 calves of interest to be traced. Of these, 208 were confirmed to have entered known rendering/slaughter channels, 4 were presumed to have entered rendering/slaughter channels, and 1 was purchased in cash through a livestock market with no buyer name or contact information (this animal was classified as untraceable. See Appendix 1). A calf was categorized as presumed to have entered rendering/slaughter channels if it passed through at least one livestock market subsequent to its original sale and could not be individually traced due to unknown resale date and new backtag, but all calves resold matching that description during an appropriate date range were purchased by known rendering/slaughter order buyers.

It was not possible to DNA test the calves that entered known rendering and slaughter channels – most were of an age in which they were likely to have been slaughtered prior to the time of the investigation. There were no calves traced to farms outside of rendering and slaughter channels.

Tracing of Birth Cohorts

Since there were essentially no records maintained on the index farm, it was necessary to compile the list of known birth cohorts using brucellosis CV tag numbers for this herd from the period 1991 to 1994. The calves vaccinated during that time period were part of the index cow’s birth cohort and tracing activities centered on finding those animals. There were 121 animals whose CV tag number and/or tattoo included them as part of the birth cohort. Of those 121 animals, 67 animals were definitively accounted for (42 were found in the index herd, removed, and tested BSE negative; 25 were identified as having left Farm A through the market system and were traced, 11 of those were reported slaughtered, 13 were classified as presumed dead, and 1 was found alive, euthanized, and tested BSE negative). Of the remaining 54 animals from the birth cohort, there may have been several that died within the index herd, but the majority likely left the herd without identification and would have been either re-tagged at the livestock market or consigned directly to slaughter without identification. To account for these remaining birth cohorts, all adult cattle that left the index farm since 1990 were traced as COI.

9

Tracing of Cattle of Interest

The investigation revealed that many animals left Farm A, arrived at markets without any identification tags, and were subsequently re-tagged at the market. Due to lack of farm records, it is unknown which of these re-tagged animals may have belonged to the birth cohort. As a result, all animals that may have left Farm A since 1990 were traced as COI. Additionally, animals from the index farm were sold not only under the index farm owner’s name and that of his wife, but also by other members of the owner’s immediate family; therefore, cattle sold from the index farm by all pertinent family members were traced. There were some older animals that left the index farm but were able to be excluded from further trace work because they were known not to have been part of the birth cohort or feed cohort of the index cow despite their being of the appropriate age. The index farm owner’s late father had maintained a herd of cattle separate from the index farm but which was added to the index farm in 1997. Complete herd test data and CV data from the GDB was obtained for the father’s herd and those animals were excluded from the tracing activities.

There were a total of 200 COI traced: 143 were reported to have been slaughtered (131 of those were confirmed as having been slaughtered), 1 is known to have died previously and was buried, 2 were found alive (1 was a known birth cohort that tested negative, 1 was determined not to be one of the cattle of interest due to her young age), 34 were classified as presumed dead, 20 were classified as untraceable. (See Appendix 1). Animals were confirmed at slaughter using GDB slaughter testing data or the hard copies of slaughter testing Form 4-54.

An animal was classified as presumed dead if records that could be used to advance the tracing of the animal were exhausted or did not exist, and the age of the animal at the time of the investigation was estimated to be at least 11 years old or older. Since the index herd was not a purebred or seedstock operation, and animals leaving the herd were unlikely to be purchased as replacement cattle, standard industry practices indicated that most adult animals that had left the herd would have been culled and slaughtered by the time they were in this age group. Additionally, this age cutoff was arrived at through review of market records and the specific years in which Farm A sold cattle through the market. An animal was classified as untraceable if all records to advance the tracing of the animal were exhausted or did not exist, and the age of the animal at the time of the investigation was estimated to be less than 11 years of age (the animal, therefore, could not be presumed dead).

Calculation of Minimum Estimated Ages

Throughout the tracing process, personnel used minimum estimated ages of the 200 COI to evaluate whether those individuals could be old enough to be part of the birth or feed cohort of the index cow. Since Farm A’s owner maintained no records on the ages of animals, GDB data assisted in assigning minimum estimated ages. Animals that were wearing brucellosis CV eartags could be aged quite accurately because the exact CV date was recorded in the GDB and those animals would have been vaccinated between 4 to 12 months of age. The GDB also contained lists of individual eartags for all animals on the

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index farm that were included in complete herd brucellosis testing in 1991, 1993, and 1994. Cattle included in those herd tests would have been at least 18 months of age at the time of the test and their minimum age today could be extrapolated from that data. Finally, the GDB also contained livestock market testing data that could also be used to assign a minimum age because the animal would have been at least 18 months of age on date the earliest brucellosis market test was conducted. The minimum ages calculated for the cattle of interest were used later in an analysis by USDA’s Centers for Epidemiology and Animal Health (CEAH) to determine the probable disposition of untraceable and presumed dead animals based on their age.

Trace Herds

Response personnel made every attempt to trace COI to their final dispositions (which, in most cases, was slaughter). If an animal was traced to a herd owner and the owner could not provide information that indicated that the animal of interest was not currently present within his/her herd, the owner’s herds were placed under hold order pending a herd inventory to determine whether or not the animal of interest had been retained. There were eight herds identified as the last traceable location of the animal of interest and were, therefore, subjected to herd inventories in an attempt to locate the animal.

When an animal of interest was located within a herd, the age of the animal was estimated using dentition and any man-made identification. If the animal fell into the appropriate age range to be a possible birth cohort or feed cohort of the index cow, the animal was removed from the herd and tested. If an animal of interest was located within the herd and fell into the appropriate age range to be a possible at-risk progeny of the index cow, the animal was sampled for DNA testing.

Trace Herd 1

The owner of Trace Herd 1 was identified as having received one of the adult COI from the index herd. Trace Herd 1 contained 909 head of cattle in multiple pastures and was placed under hold order on 7/21/05. Upon completion of herd inventory, the animal of interest was not found within the herd. A GDB search of all recorded herd tests conducted on Trace Herd 1 and all market sales by the owner failed to locate the identification tag of the animal of interest and she was subsequently classified as untraceable. The hold order on Trace Herd 1 was released on 8/8/05.

Trace Herd 2

Trace Herd 2 was identified as having received one of the adult COI from the index herd. Trace Herd 2 contained 19 head of cattle on one pasture and was placed under hold order on 7/25/05. The owner of Trace Herd 2 identified the animal of interest by her eartag while he was feeding his cattle out of a bucket and individually penned her for inspection by field personnel. While the cow was identified as one of the animals that had left the index farm, her age by dentition was estimated to be only 5 years old, which was too young to have placed her as part of the birth or feed cohort of the index animal. She was classified as found alive but determined not to be one of the COI; the hold order on Trace Herd 2 was released on 7/26/05.

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Trace Herd 3

The owner of Trace Herd 3 was identified as possibly having received an animal of interest. The herd was placed under hold order on 7/27/05. The herd inventory was conducted on 7/28/05. The animal of interest was not present within the herd, and the hold order was released on 7/28/05. The person who thought he sold the animal to the owner of Trace Herd 3 had no records and could not remember who else he might have sold the cow to. Additionally, a search of GDB for all cattle sold through the markets by that individual did not result in a match to the animal of interest. The animal of interest traced to this herd was classified as untraceable because all leads were exhausted.

Trace Herd 4

The owner of Trace Herd 4 was identified as having received one of the COI through an order buyer. Trace Herd 4 was placed under hold order on 7/29/05. A complete herd inventory was conducted on 8/22/05 and 8/23/05. There were 233 head of cattle that were examined individually by both State and Federal personnel for all man-made identification and brands. The animal of interest was not present within the herd. Several animals were reported to have died in the herd sometime after they arrived on the premises in April 2005. A final search of GDB records yielded no further results on the eartag of interest at either subsequent market sale or slaughter. With all leads having been exhausted, this animal of interest has been classified as untraceable. The hold order on Trace Herd 4 was released on 8/23/05.

Trace Herd 5

The owner of Trace Herd 5 was identified as having received two COI and was placed under hold order on 8/1/05. Trace Herd 5 is made up of 67 head of cattle in multiple pastures. During the course of the herd inventory, the owner located records that indicated that one of the COI, a known birth cohort, had been sold to Trace Herd 8 where she was subsequently found alive. Upon completion of the herd inventory, the other animal of interest was not found within the herd. A GDB search of all recorded herd tests conducted on Trace Herd 5 and all market sales by the owner failed to locate the identification tag of the animal of interest and she was subsequently classified as untraceable due to all leads having been exhausted. The hold order on Trace Herd 5 was released on 8/8/05.

Trace Herd 6

The owner of Trace Herd 6 was identified as possibly having received an animal of interest and was placed under hold order on 8/1/05. This herd is made up of 58 head of cattle on two pastures. A herd inventory was conducted and the animal of interest was not present within the herd. The owner of Trace Herd 6 had very limited records and was unable to provide further information on where the cow might have gone after he purchased her from the livestock market. A search of GDB for all cattle sold through the markets by that individual did not result in a match to the animal of interest. Additionally, many of the animals presented for sale by the owner of the herd had been re-tagged at the market effectually losing the traceability of the history of that animal prior to re-tagging. The animal of interest traced to this herd was classified as untraceable due to all leads having been exhausted. The hold order on Trace Herd 6 was released on 8/3/05.

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Trace Herd 7

The owner of Trace Herd 7 was identified as having received an animal of interest and was placed under hold order on 8/1/05. Trace Herd 7 contains 487 head of cattle on multiple pastures in multiple parts of the State, including a unit kept on an island. The island location is a particularly rough place to keep cattle and the owner claimed to have lost 22 head on the island in 2004 due to liver flukes. Upon completion of the herd inventory, the animal of interest was not found present within Trace Herd 7. A GDB search of all recorded herd tests conducted on Trace Herd 7 and all market sales by the owner failed to locate the identification tag of the animal of interest. The cow was subsequently classified as untraceable. It is quite possible though that she may have died within the herd, especially if she belonged to the island unit. The hold order on Trace Herd 7 was released on 8/8/05.

Trace Herd 8

Trace Herd 8 received an animal of interest, which happened to be a known birth cohort of the index cow, from Trace Herd 5. Trace Herd 8 consists of 146 head of cattle that were placed under hold order on 8/4/05. A herd inventory was conducted, the birth cohort was found alive in the herd, and she was purchased and euthanized. The hold order on Trace Herd 8 was released on 8/4/05. The cow was sampled on 8/5/05 and BSE tested by ELISA at NVSL. Results were negative (as reported on 8/6/05); carcass disposal was completed by alkaline digestion.

Analysis of Data on Presumed Dead and Untraceable Animals

CEAH performed an analysis of the minimum estimated ages of those COI that were classified as either presumed dead or untraceable to determine the likely disposition of those animals based on their ages. Moreover, CEAH performed an analysis of the likely disposition of the one calf that was classified as untraceable during the investigation.

The index case was a deep red, crossbred beef cow estimated to be approximately 10- years-old based on dentition. On March 16, 2006, USDA personnel exhumed the carcass of the index case, sent the head to NVSL and transported under seal the remainder of the carcass to the Alabama State Diagnostic Laboratory (ASDL). The investigators confirmed the carcass to be that of a red beef cow. The body and facial area did not contain any white markings. No identification devices were found on the cow, including any evidence of brands, tattoos, or ear tags. Additionally, on March 29, NVSL examined the head of the carcass to confirm the lack of a tag and the lack of evidence (holes or scarring) of previous tags in the ear.

The age of the index cow was estimated by examination of the dentition as 10-years-old by the accredited veterinarian. Regulatory personnel examined the dentition of the exhumed carcass and concurred with the estimate. The teeth in the head of the carcass were short with elongated necks with some incisors missing. This is consistent with the dentition of other cattle from Alabama with a known age of 10 or more years. Genetic tests were conducted at NVSL to match the NVSL-generated homogenate of the obex, the homogenate of obex from the Georgia lab, brain material from the cow head (collected by NVSL), and ear material from the cow head (also collected by NVSL). On March 23, the results for these tests indicated they all originated from the same source and confirmed that that carcass exhumed on March 16 was the index case.

Disposal of the Index Case

Following exhumation on March 16, the carcass was broken down and Federal personnel transported the head (stored on ice) to NVSL. The remainder of the carcass was placed in hazardous materials barrels and transported under seal to ASDL by Federal and State personnel.

The carcass is currently being held under seal in a secure cooler at the ASDL, pending final disposal. The head remains frozen at NVSL. Cleaning and disinfection of the site was completed following removal of the carcass.

4

At-Risk Progeny of the Index Case

2005 calf:

The index cow gave birth to a black bull calf around February or March 2005. The calf was born on the index premises. The owner took the calf to a stockyard sale in July 2005. The owner reported that the animal died at the stockyard prior to sale and the carcass disposed of in a sanitary landfill. An interview of the stockyard manager confirmed memory of that owner having a calf die at the stockyard. Stockyard records confirmed delivery of material to the landfill on that day. This trace thread is closed.

2006 calf:

At the time of death, the index cow had at her side a 2- to 3-week old red Charolais cross female calf born in February 2006. This calf was present on the premises when the investigation began. On March 16, this calf was indemnified using Animal and Plant Health Inspection Service (APHIS) funds and transported to NVSL where it is currently held in APHIS custody. ARS is developing a research protocol to study this calf. Results obtained on April 6 of a DNA analysis comparing a blood sample from the calf to tissues from the index case confirmed that this animal was the calf of the index cow. This trace thread is closed.

These two calves constitute the last two calves born to the index cow prior diagnosis of BSE.

Trace Back Investigation

Investigation of Index herd (Farm A):

The most recent owner (Farm A) purchased the index case at a stockyard in December 2004. The stockyard sheet for that day describes Farm A buying a single animal that matches the appearance of the index case. This cow was red, back tag #57, with shortsolid mouth (indicating worn incisors) and 7 months pregnant, weighing 990 lb. The owner confirmed this purchased cow is the index cow.

Based on the color/breed, age, and pregnancy status of the index case, the following criteria were used to trace the index case to its herd of origin: 1. Coat color - Only cattle described as red in color were traced as potential leads to the herd of origin. All other colors, including red with white described on the face (such as red, white-faced or red, mottled-faced, and breeds that are not red in color, such as Charolais), were excluded from further investigation. This is because the index case was solid red with no white on the head and any red cow

5

with recorded facial coloring would not be compatible in appearance with the index cow.

2. Age - Only cattle known or suspected to have been born before March 1998 (i.e., greater than 8 years of age at the time of death of the index case) were traced as potential leads to the herd of origin. To estimate the lower limits of age, cattle sold at a stockyard and identified as being 18 months of age by mouthing (the date they shed their deciduous medial incisors) will be considered to be at least two years of age on the date of sale. This takes into account that the exact age of shedding of medial incisors varies slightly among cattle and erring on the older side of the estimate of the cattle’s age will more likely increase the number of animals traced.

3. Other factors - Other factors considered in determining whether or not to pursue an animal as possibly being the index case include the recorded weight at sale, stage of pregnancy, and ages of calves. The value of these factors depends on the information obtained from interviews, sales records and other evidence used to trace the index case.

Investigation of Previous Farms/Owners Investigation of Farm B Background: Stockyard records identified the prior owner of the index cow as Farm B. The cow was one of 26 animals sold as part of a dispersal of the herd of Farm B in December 2004. Investigation: All 26 animals had been purchased between July 2004 and November 2004. The owner of Farm B was deceased by the time the index case was detected. Interview of the widow of Farm B confirmed that, due to health issues, the owner of Farm B had sold all his cattle in early 2004 then began to re-establish a herd during late 2004 before again selling out in December 2004.

Results: Stockyard records of all 26 cattle purchased by Farm B were evaluated to determine where the index cow came from. Four animals could not be ruled out as having been the index cow based on color, age, and stage of pregnancy at the time of sale. Each animal belongs to a different owner. Two additional red cows were purchased by Farm B but were too young and at the wrong stage of pregnancy at the time of sale to qualify as the index case and were excluded from further tracing.

Investigation of Farm C Background: The owner of Farm C sold a red cow with calf at its side at a stockyard on August 8, 2004, weight 1,220 lbs (total for pair). These animals were later purchased by Farm B. This animal is consistent with the weight, age, and stage of pregnancy of the index case at that time.

6 Investigation: Farm C purchased the animal in question as a yearling or bred heifer in 1997 along with two half siblings from Farm G. Of the three animals purchased, one remains on Farm C, another died several months prior to the investigation and is buried on the premises, and the third is the possible index cow being traced. The three cows were all sired by the same bull. Additionally, the possible index cow, if on Farm C, would have given birth in this herd and there would likely be calves present. On March 25, blood samples were collected from all animals on Farm C between the ages of 18 months and 8 years of age, including the known half-sibling, in order to determine if any of the animals were compatible with being first generation progeny of the index case. In addition, the known half-sibling was evaluated for genetic linkage to the index case. Samples were submitted to NVSL for DNA analysis in order to determine genetic linkages.

Results: Results received on March 6 indicated that none of the animals tested qualified as offspring or siblings of the index cow. The animal identified by the owner of Farm C as possibly related to the index cow did not genetically match the index case. No animals remained on Farm C that would qualify for additional testing. Farm C was excluded as a source of the index case, and the suspected half-sibling did not qualify as related. This trace thread is closed. Farm G stated that the cow traced to his herd had a bangle tag, although there was no evidence of a tag or prior presence of a tag in the index cow’s ear at the time of death. This trace thread is closed. Investigation of Farm D Background: The owner of Farm D sold a red cow on September 11, 2004, full mouth, 5 months pregnant, 1,015 lbs. This animal is consistent with the weight, age, and stage of pregnancy of the index case at that time.

Investigation: Farm D is a cattle dealer. He buys and sells many cattle each year. According to records, at two stockyards with which Farm D does business, he purchased 35 red cows from 23 different premises (Farms M – II) that were consistent with the index case according to age and weight between 2000 (the earliest date of availability of records) and September 11, 2004, (the date he was reported as having sold the cow being traced). This owner’s typical business practice is to purchase young cows (less than 3 years of age) that are not pregnant or recently bred, breed them, hold them until near calving, and then resell them as bred cows and cow calf pairs. He does not typically keep cows for more than a year. He does not retain calves from any of the cattle (with the exception of a single Braham cow). He is certain that the cow was not born on his premises. Because of the transient nature of cattle within this herd, and lack of suspected first generation offspring, no DNA analysis was performed on animals in Farm D. Farm D purchased a red cow from Farm M on March 17, 2004, as part of a cow and calf pair through a local stockyard. Farm M is a registered Red Angus breeder. All cattle are 7 tattooed and tagged as part of the registry process. Farm M had a few recipient cattle that were sold at approximately the same time that the animal being traced through Farm D would have been sold. All of the recipient cattle were Holsteins and were excluded based on phenotype. Because all qualifying animals on this farm are identified by both tattoo and ear tag as a requirement of registration, the farm could not have been the source of the index cow.

This trace thread is closed. Farm N consigned a cow and calf pair to Farm D on January 8, 2003, at a local stockyard. The weight of the pair at purchase was 1,140 lbs. Farm N consists of approximately 25 cows, primarily Charolais cross and black Angus cross. Farm N’s current herd was established in 1996. According to records kept at Farm N, the cow sold to Farm D produced bull calves in 1997, 1999, and 2001 and heifers in 1998, and 2000. Because this cow was small for the herd, none of her heifers were retained in this herd. The cow was listed as a red Angus-type cow that was purchased through a stockyard in 1997. The sale records for the stockyard were destroyed in a fire and therefore unavailable. Since the cow was not born in this herd, and no offspring or other related animals remained in the herd, there are no eligible animals remaining on this farm for genetic testing. This trace thread is closed. Farm O consigned a red cow to the stockyard on December 14, 2002, as a 5-month pregnant cow, weighing 1,060 lb, which was purchased later by Farm D. Farm O had purchased 118 head in early 2002, calved them out, and rebred them before selling the calves and the bred cows later that year. None of these animals remains on the farm and no calves were retained. The owner of Farm O purchased the cattle through four to five stockyards or other sources. The traced cow was not born in this herd and no animals remain on the farm that qualify for genetic testing. This trace thread is closed.

Farm P consigned two red cows to the stockyard on August 10, 2002. Farm P purchased these two cattle from Farm JJ in 2000 as part of a group of 38 heifers. There are no cattle remaining on Farm P at this time; therefore, no animals are available for genetic testing for comparison with the index cow. This trace thread is closed.

The cattle present on Farm JJ were dispersed in 2001 and a new owner began operating from the same property. The new owner did not recall the exact cattle in question but was very certain that any cattle sold from Farm JJ (under either owner) would have had ear tags in place, and if sold before the 2001 dispersal, would have been branded on the right hip. Because the index cow had no evidence of having ever been tagged or branded, this farm can be excluded as a source of the index cow. This trace thread is closed.

Farm Q sold five red cows at a stockyard on April 17, 2002, that were later purchased by Farm D. All five of these animals, according to the owner, were red Angus-type cows, between 6-and 10-years of age and sold with a calf at their side. The owner had purchased these five cows as part of a group of cattle from Farm KK. Farm Q does not keep replacement heifers. There are no eligible animals remaining on Farm Q for genetic testing and this trace thread is closed. 8 All five of the animals traced back from Farm Q were purchased from Farm KK as part of an unknown number of red Angus-type cows sold to Farm Q. Farm KK currently consists of a beef cow/calf operation with approximately 300 brood cows. The herd is a mixed breed beef herd that was acquired over a period of several years by purchasing cattle at local stockyards. The owner of Farm KK had a herd with another animal consisting of approximately 60 head of mixed breed cattle in 1998 to 1999 that had been purchased and sold out entirely to the local stockyard in either 1999 or 2000. However, he could not find any records for that sale and all stockyard records were destroyed in a fire during 2000. The owner of Farm KK stated he had not sold any cattle privately to Farm Q and did not know who purchased the cattle at the stockyard. Subsequent to the 1999/2000 dispersal, Farm KK began buying cattle again and sold all its animals in 2004. The current herd consists of brood cows that have been purchased at local stockyards since the 2004 dispersal. These cattle are not known to be related to any previously owned cattle. There are no animals remaining on Farm KK that would be appropriate for genetic testing. This trace thread is closed. Farm R consigned a red cow to the stockyard March 6, 2002. The owner of Farm R does not remember the specific cow, but has a registered Beefmaster herd and a commercial herd and does not retain commercial heifers as replacements. He purchases replacement animals to enter the commercial herd from three different stockyards. No animals are present on the farm that would be eligible for genetic testing. This trace thread is closed.

Farm S sold a red cow and calf pair to Farm D through the stockyard on March 27, 2002. Farm S sold all his cattle a year ago and has purchased new cattle. None of the original herd remains on the farm. He said he purchased the traced cow from a neighbor. He bought the neighbor’s entire herd at the time and took the traced cow directly to the stockyard. The neighbor’s farm does not have any cattle remaining. No animals remain on either farm that would qualify for genetic testing. This trace thread is closed.

Farm T consigned a red cow to the stockyard on January 9, 2002. This cow was later purchased by Farm D. All cattle on Farm T were sold in 2003. The owner of Farm T stated that he purchased three older red cows at the same stockyard in 1999 or 2000 and sold them back in 2002 or 2003. He thinks the cows had tags in their ears but is not sure. Additionally, no animals remain on the farm that would be appropriate for genetic testing. This trace thread is closed.

Three red pairs were consigned to the stockyard from Farm U on three different dates in 2001. These cows were later purchased by Farm D. The owner of Farm U has been out of the cow business since 2001. He has no memory of these cows or any other particular cattle. He stated that he would have tagged his brood cows, which is inconsistent with the lack of evidence of tagging in the index cow. There are no animals on this farm for genetic testing and this trace thread is closed. Farm V consigned two red cows to the stockyard on January 12, 2000, that were later purchased by Farm D. The owner of Farm V purchased a group of cows in 1998 from 9 the stockyard to keep on some land that he had purchased. Farm V sold all of the cows in 2000. He currently has only roping steers. No eligible animals remain on this farm for genetic testing. All stockyard records prior to 2000 were destroyed in a fire, so tracing this cow further back is not possible. This trace thread has been closed.

Two red cows were consigned to the stockyard on October 13, 2001, from Farm W, one of which was purchased by Farm D. There are approximately 50 cows of various breeds currently located on Farm W. The owner of Farm W has maintained a cow herd since 1973 and does not maintain identification on his cattle. The owner of Farm W does not recall details about the animal being traced through his farm; however, farm records indicated that the animal would likely have been one of two red cows purchased from a stockyard on May 1, 2001. Although the owner of Farm W typically retains heifers, the calves from both of these cows were sold on October 10, 2001, according to the stockyard’s records. No animals remain on this farm for genetic testing. Records collected from the stockyard indicate that the purchase weight for these traced animals was 580 and 650 lbs, both of which fall below the minimum weight defined in the SOP for investigation. These cows are excluded as the index cow based on their weights at the time of sale. This trace thread is closed. Farm X consigned two red cows to a stockyard on January 17, 2001, that were later purchased by farm D. The daughter-in-law of the owner of Farm X stated that all the cattle in the herd as of 2001 were sold in 2004 after the owner’s death. Subsequently, the owner’s son did purchase some additional cattle (unrelated to the traced animals) but these animals have also been sold. There are currently no animals remaining on the farm. No eligible animals remain on this farm for genetic testing and there are no records for purchases or sale of animals; therefore, this trace thread is closed.

A red cow and calf pair was consigned by Farm Y to the stockyard on March 11, 2001. This pair was later purchased by Farm D. Farm Y buys and sells cattle regularly and had no specific recollection of the traced cow, but when presented with stockyard records he felt reasonably sure that the animal in question was a horned Limousin cow sold with a calf at her side. He stated that all his cattle were tagged, either at the time of purchase, or by him after bringing them to his farm. Farm Y sold out all cattle during 2004 but has since begun accumulating cattle again. The index cow did not have horns and there was no evidence of dehorning or tagging. In addition, no eligible animals remain in the herd for genetic testing. This trace thread is closed.

Farm Z consigned three red cow and calf pairs to the stockyard on June 6, 2001. These animals were later purchased by Farm D. The owner of Farm Z has land (owned and rented) in many locations and occasionally runs cattle on some of this land. He reported that his practice was to buy entire herds and sell the complete herd a few months later. He sold all of his cattle accumulated from the mid-1990s during May or June of 2001 and was without cattle until later in the year when he began restocking. He has since bought and sold groups of cattle several times but keeps no records himself. There are no eligible animals remaining for genetic testing. This trace thread is closed. 10 Farm AA consigned a red cow to the stockyard on September 19, 2001. This cow was later purchased by Farm D. The traced cow was lotted-in the day before the sale and had been purchased through another stockyard earlier in the week. Sales records show the weight of the cow as 1,140 lb at the time of purchase at the previous stockyard sale, which exceeds the upper weight established for tracing in the SOP. This cow is excluded from further tracing. This trace thread is closed.

A red cow and calf pair was consigned to the stockyard by a dairy, identified as Farm BB, on November 10, 2001. This cow was later purchased by Farm D. Farm BB is comprised of a milking Holstein dairy with about 300 milking animals. The owners of Farm BB also have approximately 400 mixed breed beef cattle maintained as a cow/calf operation. Farm BB does not retain any heifers as replacements for either the dairy operation or the beef operation. They buy all their replacement cows for the dairy and buy beef cattle to raise a calf then resell the cow with a calf within a 12-to 18-month time period. When asked about records of purchased cattle, one of the owners stated that he could not locate any records prior to 2002. Farm BB utilized the services of a cattle dealer to purchase cattle at various stockyards in the region. Some of the cattle might have had ear tags prior to purchase but the owners did not put in their own ear tags when the cattle were bought. The current herd at Farm BB is comprised of various breeds of beef cattle, but they would not be the same cattle that were present in 2001, since all cows at the premises are sold within a 12- to 18-month period (with calves) after purchase. Therefore, this trace thread is closed.

Farm CC consigned a red cow to the stockyard on December 8, 2001. This cow was later purchased by Farm D. Farm CC has no cattle at this time. The owner of Farm CC has no records of cattle that he has owned and no memory of the particular animal being traced. There are no animals on the farm eligible for genetic testing. This trace thread is closed.

Farm DD consigned a red cow to the stockyard on December 12, 2001 that was later purchased by Farm D. The owner of Farm DD has no records of his cattle operation. He currently owns three cows, one bull, and two calves. All are black and none has identification. Additionally, the owner has stated that he has never owned any cows more than two years. No animals currently on the farm were present at the time the traced cow was sold and no offspring were retained from that time. There are no eligible animals remaining on this farm for genetic testing. This trace thread is closed.

Farm EE consigned a red cow to the stockyard on March 3, 2000. This cow was later purchased by Farm D. All cattle on Farm EE were sold two or three years ago. No records of sales or purchases were kept. No animals remain on this farm for genetic testing. This trace thread is closed.

Farm FF consigned a red cow to the stockyard on June 21, 2000. This cow was later purchased by Farm D. Farm FF has not kept cattle since the herd was dispersed 11 approximately three years ago. The owner of Farm FF has no knowledge or records of the cow in question other than that the cow would have been purchased through the same stockyard where it was sold. Purchase records prior to 2000 for this stockyard were destroyed in a fire. There are no eligible animals on the farm for genetic testing and this trace thread is closed. Farm GG consigned a red cow to the stockyard on June 21, 2000. This cow was later purchased by Farm D. The owner of Farm GG runs a feeding operation and normally purchases 350 to 450 lb steers and heifers for feeding out. He generally has fewer than 700 head at any one time. Farm GG reported selling the entire cow herd between late 2000 and early 2001. He has no recollection or records of the traced animal. Most of his cows at that time were purchased either through the stockyard or by private. He did not keep offspring of his cattle. No eligible animals remain on the farm for genetic testing. This trace thread is closed.

Farm HH consigned two red cows to the stockyard on September 20, 2000. These cows were later purchased by Farm D. All cattle on Farm HH were sold at that time as part of a herd dispersal and none remaining on the farm are eligible for genetic testing. This trace thread is closed. Farm II consigned a red cow and calf pair to the stockyard on October 11, 2000. This cow was later purchased by Farm D. Farm II’s owner currently has 100 to 150 cows. He formerly had Beefmaster cattle but now has a herd of mixed crossbred cattle. He normally buys cows through the stockyard or from private individuals. After he brings them to his farm, he evaluates them by close examination. If he decides to keep the animal he tags it. Those that he decides not to retain are sold at the stockyard the next week. If any animal was sold from his farm without an ear tag, it would have been one of these that he resold immediately. On review of his records, the owner believes that the cow sold at the stockyard on October 11, 2000, was one that was purchased through the same stockyard on April 3, 2000. That cow was tagged on his farm with a green bangle tag #6. There was no tag in the index cow’s ear, nor was there evidence of a either a hole or scar. This cow is excluded as the index cow based on the known presence of an ear tag. This trace thread is closed. Results: In all, 25 farms were investigated as suppliers of cows that could have supplied the index cow to Farm D. All of these farms were excluded as the herd of origin of the Index Case. Therefore the trace back from Farm D is closed. 12 Investigation into Farm E Background: Farm E sold a red cow on August 11, 2004, 2 months pregnant, weighing 790 lbs. This cow was later purchased by Farm B. This animal is consistent with the weight, age, and stage of pregnancy of the index case at that time. Investigation: Farm E purchased two cows on January 17, 2000, that matched the color, approximate age, and stage of pregnancy of the index case. These cows had been purchased from Farm K and Farm L. Farm K sold an 18-month old red heifer through a stockyard that was later purchased by Farm E. The cow in question had been tested for brucellosis at the stockyard and an official brucellosis ear tag was placed in its ear. The cow was at the minimum age for tracing at the time of sale. Because all cattle on Farm K were dispersed in 2003 and no animals remain on the farm and because the index case had not been ear tagged. This traced is closed. Farm L consigned an 18-month old red cow to a stockyard on January 17, 2000, that was later purchased by Farm E. The cow in question had been tested for brucellosis at the stockyard and an official brucellosis ear tag was placed in its ear. The cow was also at the minimum age for tracing at the time of sale. There was only one animal present on Farm L from January 2000 at the time of the investigation in 2006. Because the cow being traced did not calve in this herd there were no animals eligible for genetic testing. This trace thread is closed. Farm E indicated that he may have kept some calves from red cows. DNA testing was conducted in Herd E to determine whether offspring of the index case were present. On March 31 blood samples were collected from all cattle that qualified by age as possible progeny of the cow being traced in order to determine if they could be genetically linked to the index case. Results received on April 8 indicated that no animals qualify as first generation offspring or full siblings of the index case. This trace thread is closed.

Results: Because both animals sold to Farm E had been identified with ear tags, and because either no animals were present or no animals were eligible for genetic matching on the farms supplying Farm L neither of these animals could have been the index case. The trace thread from Farm E is closed. Investigation into Farm F Background: Farm F sold a red cow with a calf on September 1, 2004, no age or pregnancy status available, weight 890 lbs. This cow was purchased by Farm B. This animal is consistent with the color and weight of the index case at that time. Investigation: The stockyard records indicated that this cow had a Charolais Cross bred steer at its side, which was sold for slaughter. 13 The owner of farm F had purchased the cow from Farm H through the stockyard. The cow was sold as lot #87 on April 9, 2003. Farm H identified the cow as having come from two possible sources, one of which was a purchased animal that was confirmed to be a Beefmaster breed, light red in color, and branded. This cow was excluded as the index case. The other possible animal might have been raised in the herd. If it had been raised in his herd it was possible that one animal that qualified as first generation progeny would still be presenting the herd. On March 29, blood samples were collected from all animals 18 months of age or older on Farm H. Results received on April 6 indicated that none of the animals qualified as offspring of the index case, including the one animal identified by the owner as the offspring of the cow being traced. This trace thread is closed.

The owner of Farm F also purchased another red cow from Farm I on the same day as determined by stockyard records. No animals remain on the premises of Farm I to be genetically compared to the index case. This trace thread is closed.

Results: Farm F did not retain any calves from his cows so no animals were eligible for genetic comparison. This trace thread is closed.

Summary: Despite a thorough investigation of two farms that were known to contain the index cow, and 35 other farms that might have supplied the index cow to the farms where the index case was known to have resided, the investigators were unable to locate the herd of origin. The index case did not have unique or permanent identification, plus, the size and color of the cow being traced is very common in the Southern United States. Due to the unremarkable appearance of solid red cows, it is not easy for owners to remember individual animals. In the Southern United States, it is common business practice to buy breeding age cows and keep them for several years while they produce calves. Most calves produced are sold the year they are born, whereas breeding cows are sold when there is a lapse in breeding, which can occur multiple times in cows’ lives. For all of these reasons, USDA was unable to locate the herd of origin.

Statement on Texas Cow With Central Nervous System Symptoms On Friday, April 30 th , the Food and Drug Administration learned that a cow with central nervous system symptoms had been killed and shipped to a processor for rendering into animal protein for use in animal feed.

FDA, which is responsible for the safety of animal feed, immediately began an investigation. On Friday and throughout the weekend, FDA investigators inspected the slaughterhouse, the rendering facility, the farm where the animal came from, and the processor that initially received the cow from the slaughterhouse.

FDA's investigation showed that the animal in question had already been rendered into "meat and bone meal" (a type of protein animal feed). Over the weekend FDA was able to track down all the implicated material. That material is being held by the firm, which is cooperating fully with FDA.

Cattle with central nervous system symptoms are of particular interest because cattle with bovine spongiform encephalopathy or BSE, also known as "mad cow disease," can exhibit such symptoms. In this case, there is no way now to test for BSE. But even if the cow had BSE, FDA's animal feed rule would prohibit the feeding of its rendered protein to other ruminant animals (e.g., cows, goats, sheep, bison).

FDA is sending a letter to the firm summarizing its findings and informing the firm that FDA will not object to use of this material in swine feed only. If it is not used in swine feed, this material will be destroyed. Pigs have been shown not to be susceptible to BSE. If the firm agrees to use the material for swine feed only, FDA will track the material all the way through the supply chain from the processor to the farm to ensure that the feed is properly monitored and used only as feed for pigs.

To protect the U.S. against BSE, FDA works to keep certain mammalian protein out of animal feed for cattle and other ruminant animals. FDA established its animal feed rule in 1997 after the BSE epidemic in the U.K. showed that the disease spreads by feeding infected ruminant protein to cattle.

Under the current regulation, the material from this Texas cow is not allowed in feed for cattle or other ruminant animals. FDA's action specifying that the material go only into swine feed means also that it will not be fed to poultry.

FDA is committed to protecting the U.S. from BSE and collaborates closely with the U.S. Department of Agriculture on all BSE issues. The animal feed rule provides crucial protection against the spread of BSE, but it is only one of several such firewalls. FDA will soon be improving the animal feed rule, to make this strong system even stronger.

Bovine spongiform encephalopathy (BSE), the prion disease in cattle, was widely believed to have only one strain (BSE-C). BSE-C causes the fatal prion disease named new variant Creutzfeldt-Jacob disease in humans. Two atypical BSE strains, BASE (or BSE-L) and BSE-H, have been discovered in several countries since 2004; their transmissibility and phenotypes in humans are unknown. We investigated the infectivity and human phenotype of BASE by inoculating transgenic (Tg) mice expressing the human prion protein with brain homogenates from two BASE-affected cattle. Sixty percent of the inoculated Tg mice became infected after 20-22 months incubation, a transmission rate higher than those reported for BSE-C. A quarter of BASE-infected Tg mice, but none of the Tg mice infected with a sporadic human prion disease, showed presence of pathogenic prion protein isoforms in the spleen, indicating that the BASE prion is intrinsically lymphotropic. The pathological prion protein isoforms in BASE-infected humanized Tg mouse brains are different from those of the original cattle BASE or sporadic human prion disease. Minimal brain spongiosis and long incubation time are observed in the BASE-infected Tg mice. These results suggest that, in humans, BASE is a more virulent BSE strain and likely lymphotropic.

Considering that Mad Cow disease of all documented phenotypes, either the c-BSE, or the atypical h-BSE and or the l-BSE, ALL of which have been documented in North America, how many more, who knows, but they seem to be throwing all there marbles in the pot now by calling the h-type BSE 'familial'. what happens if we come up with another strain ? kinda like the sporadic FFI, that's not familial, what's that all about ? considering the many different strains of the typical scrapie 20+, and then the atypical Nor-98 Scrapie, which the USA has documented 6 cases the last i heard, and the thought of more than one strain of CWD in deer and elk, where will the next year, 4 years, 8 years, and beyond take us in the world of human and animal Transmissible Spongiform Encephalopathy and 'sound science' in the USA ? WILL the New Administration see the enfamous enhanced bse surveillance program of 2004 for what it was, a fraud, and have a 'redo' ? WE can hope i suppose. ...TSS

Both of the BSE cases ascertained in the US native-born cattle were atypical cases (H-type), which contributed to the initial ambiguity of the diagnosis. 174, 185 In Canada, there have been 2 atypical BSE cases in addition to the 14 cases of the classic UK strain of BSE2: one was the H-type, and the other was of the L-type.198

Bovine spongiform encephalopathy (BSE), the prion disease in cattle, was widely believed to be caused by only one strain, BSE-C. BSE-C causes the fatal prion disease named new variant Creutzfeldt-Jacob disease in humans. Two atypical BSE strains, bovine amyloidotic spongiform encephalopathy (BASE, also named BSE-L) and BSE-H, have been discovered in several countries since 2004; their transmissibility and phenotypes in humans are unknown. We investigated the infectivity and human phenotype of BASE strains by inoculating transgenic (Tg) mice expressing the human prion protein with brain homogenates from two BASE straininfected cattle. Sixty percent of the inoculated Tg mice became infected after 20 to 22 months of incubation, a transmission rate higher than those reported for BSE-C. A quarter of BASE strain-infected Tg mice, but none of the Tg mice infected with prions causing a sporadic human prion disease, showed the presence of pathogenic prion protein isoforms in the spleen, indicating that the BASE prion is intrinsically lymphotropic. The pathological prion protein isoforms in BASE strain-infected humanized Tg mouse brains are different from those from the original cattle BASE or sporadic human prion disease. Minimal brain spongiosis and long incubation times are observed for the BASE strain-infected Tg mice. These results suggest that in humans, the BASE strain is a more virulent BSE strain and likely lymphotropic.

About Me

My mother was murdered by what I call corporate and political homicide i.e. FOR PROFIT! she died from a rare phenotype of CJD i.e. the Heidenhain Variant of Creutzfeldt Jakob Disease i.e. sporadic, simply meaning from unknown route and source. I have simply been trying to validate her death DOD 12/14/97 with the truth. There is a route, and there is a source. There are many here in the USA. WE must make CJD and all human TSE, of all age groups 'reportable' Nationally and Internationally, with a written CJD questionnaire asking real questions pertaining to route and source of this agent. Friendly fire has the potential to play a huge role in the continued transmission of this agent via the medical, dental, and surgical arena. We must not flounder any longer. ...TSS